Privacy Notice

1. Welcome to Med ResQ’s privacy notice. We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after any personal data that you provide to us, whether as part of your visit to this website (regardless of where you visit it from), when you communicate with us, or when we provide services that you benefit from. This policy also tells you about your privacy rights and how the law protects you.
Purpose of this privacy notice
2. This privacy notice aims to give you information on how we collect and processes your personal data through your use of this website.
3. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
4. Med ResQ provides a broad range of services, meaning that in certain circumstances we are a data controller (meaning we have the ultimate responsibility for the data we collect) and in other circumstances we are a data processor (meaning we are handling data on behalf of a third party who is the controller of that data). This privacy policy applies only where we are handling data as a data controller. Where we are acting as a data processor we will process personal data under a contract with the data controller and the data controller has ultimate responsibility for our use of that data.
5. Further information regarding what is meant by ‘data controller’ and ‘data processor’ can be found here: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/controllers-and-processors/controllers-and-processors/what-are-controllers-and-processors/.
Controller
4. The Company Med ResQ Ltd is the controller and is responsible for your personal data (collectively referred to as “the Company”, “we”, “us” or “our” in this privacy notice). Med ResQ is registered with the Information Commissioners’ Office under registration number ZB394180.
5. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us directly via the contact details provided.
6. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
7. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
8. We keep our privacy policy under regular review and any changes will be published on our website. If there are material changes to this policy we will strive to notify you by email. Your ongoing use of our website, and ongoing communication with us will signal your acceptance to the version as appears on our website from time to time.
Third-party links
8. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
9. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data), or where the identity has been transformed (pseudonymised).

10. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Special Category Data includes any data relating to your health, racial or ethnic origin, religious beliefs, sex life or sexual orientation, and/or genetic data. We only ever collect this type of data where we specifically require it to provide you with one of our services. We only collect the minimum amount of this kind of data that is needed to enable us to provide our services to you.

11. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
How is your personal data collected?
12. We use different methods to collect data from and about you including through direct interactions. For example, you may give us your identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
How we use your personal data, also known as lawful bases
13. To lawfully process your data we must have a ‘lawful basis’ under which we collect, store, and process that data. We must make this lawful basis clear to you at the time we collect your data.

14. The six lawful bases are as follows:
• Consent – where you give us your clear consent for us to process your personal data for the purposes we outline
• Contract – where we are processing your personal data to enable us to comply with a contractual obligation to you, or to enable us to take steps necessary to enter into a contract with you
• Legal obligation – where we are processing your personal data to enable us to comply with a legal obligation we have to you, or a third party (for example, to report to HMRC regarding payments made or received)
• Vital interests – where we are processing your personal data to protect your life
• Public task – where we are processing your personal data to perform a task in the public interest, or for official functions outlined in law
• Legitimate interest – where we, or a third party, have a legitimate interest in processing your personal data and, in doing so, your rights are not unduly impacted.

15. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: –
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where we are providing, or arranging for, emergency medical care to safeguard your life.

16. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
Opting out
17. Where we are relying on the lawful basis of consent you have the right, at any time, to remove your consent. This also applies where we are processing your data under the lawful basis of legitimate interests. To opt-out please contact us using the contact details in this policy.
Change of purpose
18. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
19. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
20. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
21. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
22. We will share your personal data with selected third parties who assist us in the performance of our services. These can include sub-contractors, government agencies and healthcare providers. This may involve transferring your data (including special category data) outside the European Economic Area (EEA).

23. Where we transfer your personal data (including special category data) with third parties based outside of the EEA we will, so far as we can, ensure that we put in place contractual and technical arrangements with them to ensure the security and integrity of any personal data processed by them on our behalf. We will also only share with them such personal data as we, in our professional opinion, determine they need to perform the services we are asking them to perform on our behalf. In some circumstances it is not possible to ensure that a similar degree of protection is afforded to it as this is entirely dependent on the local data management laws for country in which you are in or the destination country that you wish to be transferred to but you acknowledge that where our services are being provided in countries outside of the EEA, we may not be able to put in place such contracts and protections as would be normal within the timescales required to provide the services, especially where the services relate to medical care that is required urgently.
Data security
23. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

24. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
25. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

26. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

27. In some circumstances you can ask us to delete your data. In some circumstances we may anonymise or pseudonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
28. Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights are to: –

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

29. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

30. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

31. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.